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Enormous variation exists internationally in the regulation of nutrition and health messages on the food label. For the consumer, the health claim on the label becomes a value‐added point of product differentiation. Therefore, for the food industry, access to a health claim is a key marketing variable. It is important to understand the role of the public policy process in establishing health claims as developing nations mature and choose an approval process to advance their own food regulatory environment. Their choice of approach, and the type of participants contributing to the process, will influence the type of health claim outcome and the latitude of marketing permitted on the food label. This paper identifies and compares the regulatory approaches, in effect in early 1977, used to establish health claims in Japan, Australia and the European Union. There does not seem to be a clear international “lead” nation regulatory model for health claims, and this suggests global economies of scale are elusive for product development and marketing based on health claims.

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